Declare 2.1 End-of-Life & Circularity Documentation Guidance: Residual and Non-Circular Pathways (Hazardous Substances, Energy Recovery, Landfill)

Last updated September 24, 2026

Introduction

The Declare 2.1 program update expands the options for reporting end-of-life and circularity pathways for products. This page provides practical guidance to help manufacturers identify the information and/or documentation that may support their selected Residual and Non-Circular Pathways.

These pathways describe end-of-life management where materials cannot currently be recovered through circular systems or require specialized management. A product may have both circular and non-circular end-of-life pathways when different portions of the product have different management outcomes.

This is living guidance and will be updated as Living Future gains experience with implementation of Declare 2.1.

How to Use This Guidance

The Declare 2.1 Program Manual defines each End-of-Life & Circularity pathway and the information manufacturers must disclose. This page provides examples of documentation that may help demonstrate or support those pathways.

You do not need to create a new document specifically for Declare. Existing product, technical, program, certification, testing, or other documentation may be appropriate when it provides relevant information or evidence.

The examples on this page are illustrative, not exhaustive. Different products and industries may have different types of documentation that demonstrate or support the same pathway.

Not every pathway requires supporting documentation. The platform identifies when supporting documentation is requested. If documentation is requested and you have information that is not listed here, you may submit it with a brief explanation of how it supports your selected pathway.

General Principles

When selecting an End-of-Life & Circularity pathway:

Use existing information and documentation whenever possible.
Make sure the information or documentation relates to the declared product or applicable product component.
Report the pathway based on the realistic end-of-life management options for the product.
Where a pathway is geographically limited, provide information that establishes the applicable geographic scope.
A single source may provide useful information for more than one pathway.
You may provide multiple sources when no single source provides all the relevant information.

When in doubt, provide the documentation you have and explain how you believe it supports the selected pathway. Living Future may request additional information or clarification when needed to understand the claim.

Intermediate Materials and Components

Some Declare products are intermediate materials, components, or assemblies intended to be incorporated into other products. In these cases, consider whether the selected pathway applies to the declared product itself or depends on the design, function, or end-of-life management of the finished product.

For example, a component may have its own established reuse or recycling pathway even though the repairability or disassembly of the finished product depends on how that component is incorporated. Manufacturers should select pathways based on characteristics and recovery options that can reasonably be attributed to the declared product or component.

Where a pathway depends primarily on the design or function of the finished product, the finished-product manufacturer may be better positioned to report that pathway.

Hazardous Substances

The Program Manual applies this pathway when a product, or a portion of a product, is considered hazardous to humans or the environment and requires specific end-of-life processing to mitigate the risk of exposure to hazardous ingredients.

The Program Manual identifies different regulatory references based on where the product is manufactured:

Products manufactured in the U.S. should refer to U.S. RCRA 40 CFR parts 260–273 for the definition of hazardous waste.
Products manufactured outside the U.S. should refer to Annexes I, III, and VIII of the OECD Basel Convention.

The Declare submission asks manufacturers to provide:

Applicable product scope: the entire product, an assembly, or specific component(s)
Hazardous components
Applicable regulatory classification
Required end-of-life management method
Supporting documentation, such as a URL or document reference

What could I use as evidence?

You might already have:

Applicable regulatory classification
Safety Data Sheets (SDS), where relevant
Product composition information
Regulatory documentation
Waste classification information
Instructions or requirements from an authorized waste-management provider
Documentation identifying required hazardous-waste treatment or disposal
Other information supporting the applicable classification and management method

Helpful to know

Documentation should help establish both the applicable hazardous classification and the appropriate end-of-life management method.

Where a hazardous component represents only a portion of the product, identify the applicable component consistent with the Product Scope selected in the platform.

The required end-of-life management method should reflect how the hazardous component or product is to be managed to mitigate the relevant hazard. Where applicable, supporting information may also identify the collection or waste-management pathway available for that material.

Example: A product contains a component classified as hazardous waste under the applicable regulatory framework. The manufacturer provides the relevant regulatory classification and documentation identifying the required hazardous-waste treatment or disposal method. These existing materials could support the Hazardous Waste pathway.

Energy Recovery

The Program Manual applies this pathway when a product or component is directed to a waste-to-energy, biomass energy recovery, cement kiln co-processing, or similar process that recovers energy value but does not preserve material value.

The Declare submission asks manufacturers to provide:

Applicable product scope: the entire product, an assembly, or specific component(s)
Approximate percentage by weight represented by the pathway
Energy recovery type
Pathway availability: widely available, available in some regions, limited availability, or pilot/emerging
Supporting documentation, such as a URL or document reference

What could I use as evidence?

You might already have:

Documentation from an energy-recovery facility
Facility waste-acceptance criteria
Waste processor documentation
Manufacturer take-back information identifying energy recovery as the destination
Documentation from a cement kiln or other co-processing facility
Biomass energy recovery program information
Waste-to-energy program information
Relevant product or material specifications
Other information demonstrating an appropriate energy-recovery pathway

Helpful to know

The ability of a product to burn does not, by itself, demonstrate that it has an appropriate Energy Recovery pathway. The pathway should identify an actual energy-recovery process through which the product or component can be managed.

Where possible, documentation should identify the type of recovery process or facility that accepts the product or material and, where relevant, any applicable acceptance conditions.

Energy recovery recovers energy value rather than preserving the material for use as a secondary raw material. Where a product or component has a qualifying material-recovery pathway, that pathway may be reported separately under the applicable Circular Recovery Pathway.

Example: A manufacturer has documentation from a waste processor confirming that a particular product is accepted for cement kiln co-processing. The processor's documentation, together with product information identifying the applicable product, may support an Energy Recovery selection.

Landfill

The Program Manual applies this pathway when a product or product component is expected to be disposed of in a landfill at the end of its useful life.

The Declare submission asks manufacturers to provide:

Applicable product scope: the entire product, an assembly, or specific component(s)
Estimated percentage by weight requiring landfill disposal
Reason a higher-value recovery pathway is not currently available

What information should I provide?

When selecting Landfill, provide the information requested in the platform:

Applicable Product Scope: Identify the product, assembly, or component to which the landfill pathway applies.
Disposal Fraction: Report the approximate percentage by weight expected to require landfill disposal.
Reason Higher-Value Recovery Is Not Currently Available: Select the reason that best describes the current end-of-life situation.

Possible reasons include:

Technical limitations
Contamination
Infrastructure unavailable
Regulatory constraints
Economic constraints
Other

Supporting documentation is not required for the Landfill pathway. Manufacturers should provide the best available information based on their knowledge of the product and its realistic end-of-life pathways.

Helpful to know

Manufacturers are not expected to demonstrate that no recovery option exists anywhere. The purpose of the Landfill selection is to identify the portion of the product expected to require landfill disposal and the reason a higher-value recovery pathway is not currently available.

Landfill may coexist with other End-of-Life pathways when different portions of a product have different management outcomes. For example, a product may have a take-back or recycling pathway for some components while other components are expected to be landfilled. In this situation, the manufacturer can report the applicable recovery pathway(s) and identify the remaining portion as landfill.

Manufacturers do not need to identify every possible disposal scenario. Report the pathway based on the realistic end-of-life options for the product.

How Much Documentation Is Needed?

There is no single document type that is appropriate for every Residual or Non-Circular pathway. The appropriate information or documentation that is useful will depend on:

The pathway selected
The declared product and applicable component
The nature of the end-of-life management pathway
The availability of the pathway
Geographic considerations
The documentation normally maintained by the manufacturer or other responsible party

Use the documentation you already have whenever possible. You do not need to create a new document specifically for Declare unless the Program Manual specifically requires supporting documentation.

For example:

Regulatory classification or waste-management information might support Hazardous Waste.
Facility acceptance or waste-processor information might support Energy Recovery.
Landfill does not require supporting documentation; manufacturers should provide the information requested in the platform based on their knowledge of the product and its realistic end-of-life pathways.

Different types of information and documentation can be appropriate for the same pathway, depending on the product and the information available.

Supporting documentation submitted with a Declare submission is used for program review and is not currently published on the Declare label or product listing.

What If My Documentation Is Not Listed?

The examples on this page are not an exhaustive list of acceptable information or documentation.

If supporting documentation is requested for your selected pathway and you have information or documentation that is not listed here but provides relevant support, submit it with a brief explanation of how it supports your response.

Living Future will continue to expand this guidance as questions and examples emerge through implementation of Declare 2.1.

Related Guidance

Getting Help

If you encounter a situation that is not addressed here, please share the question with the Declare team at declare.support@living-future.org.